the "n"-word nearly 400 times.
According to Mr. Rowe, Sormenschein attorneys Martin
Gold and Ray Heslin engaged in some kind of conspiracy with the defendants to concealthese emails from Plaintiffs in order to hurt their case, as part of some purported broaderconspiracy to perpetuate racism in the music industry.
These accusations against my former Sonnenschein partners are patently preposterous to
me. Certainly, I have no knowledge of any such conduct, never engaged in or assisted in
such conduct, and have absolutely no reason to believe that there is a shred of truth to
5.Mr. Rowe's supporting declaration specifically mentions me in connection with any
alleged fact only once, in only one sentence in one paragraph, which reads in its entirety
"Attorneys Martin Gold, Ray Heslin, Richard Primoff, Christine Lepera
and Carl Aron, after taking over $200,000 for email discovery andcompelling us to wait, patiently, attorneys Gold, Heslin, Prirnoff andLepera advised that nothing had been found as a result of the emails
searched. When this was reported to me, I could tell that Mr. Gold, Mr.
Primoff, and Mr. Heslin were not being truthful but I had no proof at that
time. (DeclarationT 9)
I have no recollection of any such communication, nor any knowledge of emails that are
of the nature described vaguely by Mr. Rowe's motion. I was not involved in email
discovery and the details of that process.
To the extent that Mr. Rowe is insinuating that I had any knowledge of or participation in
his theoretical "conspiracy" his insinuation is wholly fabricated. It is in fact outrageous
In 2010 Mr. Rowe published a book entitled "What Really Happened to Michael Jackson the King of Pop, The
Evil Side of the Entertainment Industry" (" Rowe's Book" ) At pages 89 —91 of his book Mr. Rowe wrote that he
learned about these "emails" in this case in July of 2002.
title and relevant pages attached hereto as Ex. A.